Twenty files and a tick sheet
Each month your compliance officer, or an external consultant, samples a batch of files. For each one they open the client record, find the fact find, find the quotes obtained, find the demands and needs statement, check the documents were issued, read the file notes, and tick a review sheet. Half the time goes on finding things. A document is filed under the wrong policy. A note is in the handler's email, not the system. The reviewer emails the handler to ask where the quotes are.
The review sheet is a Word document or spreadsheet. Results are collated by hand at the end of the quarter, and the same findings keep coming up for the same handlers.
Why reviewing is mostly searching
Broking files are not stored as a checklist. They are a collection of documents, notes and emails attached to a client, a policy or a transaction, depending on who filed them. The review criteria are fixed, but the file layout is not. So every review begins with assembling the file, which is the least skilled part and takes the most time.
- Documents are filed against the client in one case and against the policy in another.
- Key items live in email rather than the broking system.
- Review sheets are not linked to the files, so findings are hard to track over time.
- Remedial actions are agreed by email and not followed up.
What slow reviews cost
Fewer files get reviewed than your compliance plan would like. Findings arrive long after the sale, when the handler has forgotten the case. Patterns across handlers or products are only visible at quarter end. And remedial work slips because there is no list of what was agreed.
A pre-check before the reviewer opens the file
- The sample is drawn from your broking system by the rules your compliance team sets, such as by handler, product or sale type.
- For each sampled file, the relevant documents, notes and emails are gathered into one view, wherever they are filed.
- Each required item on your review checklist is checked for presence: fact find, quotes, demands and needs, documents issued, key dates.
- Simple consistency checks run, such as whether the policy bound matches one of the quotes on file or whether documents were issued after inception.
- The reviewer gets a structured review form with the pre-check results shown and the documents one click away, and records their own judgement on each question.
- Findings and remedial actions are assigned to the handler with a due date, and tracked until closed.
- Results roll up into a dashboard by handler, product and finding type.
The pre-check never passes or fails a file. It tells the reviewer what is there and what is not. The judgement on suitability and conduct is theirs.
Where the reviewer's time goes
| Part of the review | Today | With the pre-check |
|---|---|---|
| Assembling the file | Manual search | Done before review |
| Is each item present? | Checked by eye | Shown on the form |
| Is the advice suitable? | Reviewer judgement | Reviewer judgement |
| Remedial actions | Assigned and tracked | |
| Trends | Collated at quarter end | Dashboard |
A review process that keeps up
Reviewers start each file with it already assembled, so their time goes on judgement rather than searching. Handlers get findings while the case is fresh. And the compliance officer can see, month by month, whether the same gaps keep appearing, which is far more useful than a quarterly spreadsheet.
Does your file review look like this?
- Most review time goes on finding documents.
- Review results live in separate Word files or spreadsheets.
- Remedial actions are agreed by email and not tracked.
- You only see patterns across handlers at quarter end.